This Privacy Policy explains what Personal Data is collected when User use Content Office mobile application (Application), and how such Personal Data will be processed and shared.

BY USING CONTENT OFFICE AND SERVICES YOU CONFIRM AND ASSERT THAT YOUR USE OF AFOREMENTIONED SHALL COMPLY WITH THE REQUIREMENTS OF TERMS OF SERVICE. If you disagree with this assertions and promises, you must (a) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android) and (b) delete the Content Office from your devices.

Owner and Data Controller

Content Office, Eendrachtsweg 30b, Rotterdam, The Netherlands. 3012LC Owner contact email: admin.services@contentoffice.team

General

Content Office acknowledges the privacy of Users and makes efforts to protect them against any unlawful processing of Personal data. Content Office applies all necessary relevant technical and organizational measures to protect User’s Personal data in accordance with the effective legislation. The processing includes protection against unauthorized or illegal processing and against accidental loss, destruction or damage while applying suitable technical and/or organizational measures.

Although Content Office will take diligent efforts to ensure safe storage and processing of Personal data, Content Office cannot guarantee it to be 100% secure and risk-free. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User information at any time.

Types of Data collected

Data provided by User. When User register for and/or use Service User provide Content Office with email address and password.

Data provided by third parties.

When User decide to log in using third party service (Instagram) Content Office get personal data from respective User’s account. This includes User’s name and Instagram ID. For more information, please refer to the policies of third party services chosen for log in.

Device data.

Content Office collect data from User’s mobile device. Examples of such data include: device settings, model of a device, hardware ID, operating system, language settings, IP address, time zone.

Usage data.

Content Office record how User interact with Service. For example, Content Office log User’s taps on certain areas of the interface, the features, and content User interact with, how often User use the Content Office.Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Content Office do not use any Cookies or other tracking tools.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre- contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:

Provision of service

Owner collect Personal Data to provide service to its Users. It includes enabling User to use Content Office and services embedded in a seamless manner and preventing or addressing service errors or technical issues.

Account creation

Owner process Personal Data to allow User to register account for application in order to receive full access to Content Office.

Management of accounts and provision of customer support

Owner process Personal Data to respond to User’s requests for technical support, service information or to any other communication that User initiate. This includes accessing User’s account to address technical support requests. Owner may send User notifications or emails about the performance of service, security, payment transactions, notices regarding Terms of Service or this Privacy Policy.

Sending of marketing communications

Owner process Personal Data for marketing purposes. User may receive information about products, such as for example, special offers. Content Office may also send push notifications or e-mails for marketing purposes. To opt out of receiving push notifications, User need to change the settings in app or on device.

To enforce our Terms of Service and to prevent and combat fraud

Owner use Personal Data to enforce agreements and contractual commitments, to detect, prevent, and combat fraud. Content Office may share User’s information with others, including law enforcement agencies (in particular, if a dispute arises in connection with Terms of Use).

Researching and analyzing of use of the service

Owner perform researching and analyzing to, maintain, improve, innovate, plan, design, analyze operations, and to modernize Content Office. This data is also used to test and improve offers and for statistical analysis purposes. It allows to better understand what features Users like more, what categories of Users use Content Office .

Communication regarding use of Service

Owner may communicate with User by push notifications or e-mails. Such communicating may include messages and reminders encouraging User to use Content Office, or other information about Content Office. User may opt out of receiving push notifications by changing the settings on the mobile device.

Owner may collect data concerning the date and time when the message was viewed by User, as well as when User interacted with it, such as by clicking on links included in the message.

Detailed information on the processing of Personal Data

Personal Data is collected for the following general purposes:

Beta Testing

Content performance and features testing (A/B testing)
Hosting and backend infrastructure

Infrastructure monitoring

Managing contacts and sending messages

Managing support and contact requests

Registration and authentication

More details list about the using services read here.

Sharing of Personal Data

Owner sharing Personal Data with aforementioned third parties that helping operate, provide, improve, integrate, customize, support, and market service.

In addition, Owner may use and disclose Personal Data to enforce Terms of Service, to protect Owner’s rights, privacy, safety, or property, and/or that of Owner’s affiliates, Users or others. Owner may use and disclose Personal Data when respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

As mentioned above, we use SendGrid for e-mail address management and sending of messages. Please be aware that SendGrid use web beacons in emails to recipients delivered using the SendGrid platform. These web beacons track certain behavior such as whether the email sent through the SendGrid platform was delivered, opened, clicked on, whether it bounced or was treated as spam. SendGrid privacy policy is available here.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

In order to exercise their right User have to request from the Owner at any time. Upon request the Owner provides the information free of charge. However, Owner may charge a reasonable fee if request is clearly unfounded, repetitive or excessive. Alternatively, Owner may refuse to comply with User’s request in these circumstances.

Upon filing of a request by an authorised person, the notarised power of attorney must be attached to the request. In case of death of the natural person, his / her rights are exercised by his / her heirs and the certificate of heirs shall be attached to the request. The heritage should be confirmed by respective certificate, issued in the death person’s jurisdiction.

Owner shall review and pronounce on the request within 1 month as of its filing. This period may be extended by further two months, if necessary. For example, if User request is particularly complex or User have made a number of requests. The Owner shall inform the User as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the User files a request by electronic means, the information is provided electronically, if possible, unless the User has requested otherwise.

The Owner provides an answer to the requesting person taking into account their preferred form for the provision of the information (orally or in writing - as a hard copy of electronically). Where data do not exist or their provision is forbidden by law, access of the requesting party to such data is refused. If the requesting party is not satisfied with the response received and / or believes that their rights related to Personal Data protection were violated, they are entitled to exercise their right to defence.

Additional information about Data collection and processing

International data transfers

The Owner may transfer and maintain on servers or databases some of User’s Personal data outside the European Economic Area (EEA), in particular in the United States of America.

The countries to which Personal Data transferred may not have the same data protection laws as EEA. Nevertheless, Owner take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure adequate protection of Personally identifiable data.

Age limitation

Owner do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at admin.services@contentoffice.team.

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Latest update: May 13, 2019

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.